Effective date: 05/15/2024
POLICIES AND PROCEDURES MANUAL FOR TAG LENDING GROUP, LLC
(Mortgage Lender NMLS ID: 2329372)
335 S. Biscayne Blvd Ste #2809, Miami, FL 33131
860-462-7737– NMLS # 2329372
SECTION 1: INTRODUCTION
1.1 PURPOSE
The Policies and Procedures Manual outlines the standards and guidelines for conducting lending and brokering activities in the mortgage loan business at Tag Lending Group, LLC. This manual serves as a reference for all employees and agents to ensure compliance with state and federal regulations, maintain ethical practices, and deliver excellent customer service.
1.2 SCOPE
This manual applies to all Tag Lending Group, LLC employees and agents involved in mortgage lending and brokering activities, including loan originators, underwriters, processors, and customer service representatives.
1.3 SCOPE COMPLIANCE WITH STATE REGULATIONS
Tag Lending Group, LLC is committed to adhering to all applicable regulations of the Commonwealth of Pennsylvania as stated in § 46.2 of the Mortgage Protection Act.
SECTION 2: ADVERTISING POLICY
2.1 FALSE OR MISLEADING ADVERTISING
Tag Lending Group, LLC strictly prohibits engaging in false or misleading advertising related to mortgage loan products. All advertising materials must be accurate, transparent, and comply with the Pennsylvania Mortgage Protection Act and other relevant regulations.
SECTION 3: DISCLOSURES OF APPLICANT POLICY
3.1 DISCLOSURE FORM REQUIREMENTS
3.1.1 Tag Lending Group, LLC shall disclose the following information to applicants on a form prescribed by the Department:
(a) Whether the lender providing the loan will escrow applicable property taxes and hazard insurance.
(b) If Tag Lending Group, LLC is a lender with the ability to directly lock in a loan interest.
(c) Whether the loan contains a variable interest rate or balloon payment feature.
(d) Whether the loan includes a prepayment.
(e) Whether the loan has a negative amortization.
SECTION 4: TIMING AND ISSUANCE OF DISCLOSURE FORM POLICY
4.1 TIMING OF DISCLOSURE FORM ISSUANCE
Tag Lending Group, LLC shall sign and date the disclosure form and deliver or mail it to the applicant within three business days after receiving or preparing the application.
SECTION 5: REQUIRED REDISCLOSURES POLICY
5.1 UPDATING DISCLOSURE FORM
Tag Lending Group, LLC shall issue an updated disclosure form at the time the licensee knows or reasonably should know that the initial disclosure form is inaccurate.
SECTION 6: APPLICANT ACKNOWLEDGEMENT AND RETENTION POLICY
6.1 Applicant Signature and Retention Disclosure Form
6.1.1 Tag Lending Group, LLC shall require the applicant to sign and date the disclosure form within ten business days after delivery or mailing.
6.1.2 The original executed disclosure form must be retained in the applicant's loan
SECTION 7: DUPLICATION POLICY
7.1 DUPLICATION OF DISCLOSURE FORM
If the lender making the loan elects to provide the required disclosure form, Tag Lending Group, LLC, as a broker, is not required to provide the same disclosure form to the applicant.
SECTION 8: EVALUATION OF APPLICANT ABILITY TO REPAY POLICY
8.1 DETERMINING THE ABILITY TO REPAY
8.1.1 Tag Lending Group, LLC may not offer a loan without reasonably determining that the applicant will have the ability to repay the loan according to its terms and conditions by final maturity at the fully indexed rate, assuming a fully amortized repayment schedule.
8.1.2 In performing an analysis to determine the applicant's ability to repay, Tag Lending Group, LLC shall consider, verify, and document:
(a) The income of the applicant.
(b) The fixed expenses of the applicant.
8.1.3 When performing income verification, Tag Lending Group, LLC is only required to verify the income that the applicant chooses to rely upon to repay the offered loan.
8.1.4 In evaluating an applicant's ability to repay, Tag Lending Group, LLC may consider and document supplemental information provided by the applicant that demonstrates their ability to repay, provided the supplemental information is reasonably related to the applicant's ability to repay.
8.1.5 Tag Lending Group, LLC may not primarily rely on the sale or refinancing of an applicant's collateral to determine their ability to repay the offered loan.
8.1.6 All records, worksheets, and supporting documentation used in the ability to repay analysis shall be maintained in the applicant's loan file.
8.1.7 Tag Lending Group, LLC shall not ignore facts or circumstances that indicate an applicant's inability to repay the offered loan.
8.1.8 An applicant may be presumed to have the ability to repay if the offered loan meets any of the following characteristics:
(a) Is insured by the Federal Housing
(b) Is guaranteed by the United States Department of Veterans Affairs.
(c) Is originated or approved for purchase by the Pennsylvania Housing Finance.
(d) Is the subject of a written finding by a United States Department of Housing and Urban Development approved counseling agency indicating a reasonable expectation of the borrower's ability to repay.
SECTION 9: REVERSE MORTGAGE POLICY
9.1 EXEMPTION FROM CERTAIN DISCLOSURES AND REQUIREMENTS
Tag Lending Group, LLC is exempt from complying with subsections (b), (g), (i), and (j)(3) when offering or making reverse mortgages to applicants.
SECTION 10: MATERIAL CHANGES AND ABILITY TO REPAY POLICY
10.1 NOTIFICATION OF MATERIAL CHANGES
10.1.1 If there is a material change after Tag Lending Group, LLC has performed the ability to repay calculation required by subsection (g), the licensee shall immediately:
(a) Send a notice to the applicant disclosing the material change and that it may affect their ability to repay the offered loan if the licensee is a broker.
(b) Perform another ability to repay analysis in accordance with subsection (g) if the licensee is a lender.
SECTION 11: LOAN TRANSACTION PROHIBITIONS POLICY
11.1 PROHIBITED PRACTICES
Tag Lending Group, LLC may not engage in the following practices:
(a) Advising or implying to an applicant that their income is irrelevant to the loan transaction.
(b) Recommending or implying that an applicant should default on any existing contract or financial obligation.
(c) Advising or inducing an applicant to refinance an existing loan or enter into a new financial obligation without performing the ability to repay analysis required by subsection (g).
(d) Offering a covered loan without advising the applicant about other qualifying loan options offered by Tag Lending Group, LLC.
(e) Advising or implying that an applicant should ignore any required disclosures or regarding the importance of any document execution.
(f) Engaging in the improper execution of any document, including blank spaces in signed documents, witness absence during signature witnessing, or unauthorized document execution.
(g) Submitting or encouraging the submission of false or misleading information in any loan transaction.
(h) Improperly influencing appraisers or entities related to the mortgage loan business.
(i) Obtaining hazard insurance required for a loan for an applicant at loan consummation without providing the applicant with the opportunity to secure their own hazard insurance.
(j) Paying or receiving compensation from unlicensed individuals engaged in the mortgage loan business.
SECTION 12: LOAN FUNDING POLICY
12.1 LOAN FUNDING OBLIGATION
12.1.1 Tag Lending Group, LLC shall not refuse or fail to fund a consummated loan, except when an applicant rescinds the loan in accordance with 12 CFR 226.15 or 226.23.
12.1.2 Tag Lending Group, LLC shall fund a consummated loan in a reasonable time period after consummation or in accordance with any commitment or agreement with the applicant.
12.1.3 If an applicant has a right of rescission under 12 CFR 15 or 226.23, Tag Lending Group, LLC is not required to fund a consummated loan until after the applicable rescission period has ended.
12.2 LOAN DISBURSEMENT
Tag Lending Group, LLC shall disburse loan funds to third parties in accordance with any commitment or agreement with the applicant.
SECTION 13: RECORD KEEPING POLICY
13.1 RECORD MAINTENANCE
Tag Lending Group, LLC shall maintain comprehensive records of all loan transactions, including application forms, disclosures, borrower information, and supporting documentation.
13.2 RETENTION PERIOD
Tag Lending Group, LLC shall retain loan records for a period of no less than [Insert Retention Period] years, as required by applicable laws and regulations.
SECTION 14: TRAINING AND EDUCATION POLICY
14.1 EMPLOYEE TRAINING
14.1.1 All employees involved in mortgage lending and brokering activities shall receive training on the policies and procedures outlined in this manual.
SECTION 15: REPORTING POLICY
15.1 REPORTING TO REGULATORY AUTHORITIES
Tag Lending Group, LLC shall submit any required reports or disclosures to the Department of Banking and Securities as mandated by applicable regulations.
15.2 INTERNAL REPORTING
Tag Lending Group, LLC shall implement an internal reporting mechanism to track and monitor complaint data, regulatory compliance, and operational performance.
SECTION 16: MONITORING AND COMPLIANCE POLICY
16.1 INTERNAL AUDITING AND MONITORING
16.1.1 Tag Lending Group, LLC shall conduct regular internal audits and monitoring to ensure adherence to policies and procedures and compliance with state and federal regulations.
16.1.2 Any identified deficiencies or non-compliance issues shall be promptly addressed and rectified.
SECTION 17: CONTINUOUS IMPROVEMENT POLICY
17.1 POLICY REVIEW AND UPDATES
Tag Lending Group, LLC shall periodically review and update this Policies and Procedures Manual to ensure alignment with current regulations and industry best practices.
17.2 FEEDBACK
Tag Lending Group, LLC welcomes feedback from employees, customers, and stakeholders on the effectiveness and relevance of the policies and procedures outlined in this manual.
SECTION 18: CONTACT INFORMATION
18.1 COMPLIANCE OFFICER
For questions or concerns related to this Policies and Procedures Manual or regulatory compliance, employees may contact the Compliance Officer:
Anthony Angelillo
HR@TagLendingGroup.com
TAG Lending Group, LLC
End of Policies and Procedures Manual
Note: This Policies and Procedures Manual is subject to change without prior notice. For the latest version, employees should refer to the company's official documentation or contact the Compliance Officer directly.
CEO/Founder
Anthony Angelillo
